The authors of this letter previously attended open houses related to the Official Plan update for the City of Guelph and communicated via telephone with Guelph planning staff concerning livestock within the City. Questions related to livestock use within the City limits have not been explicitly answered within the proposed Official Plan, were not answered verbally or answered within background documents for the Plan update. In general terms, questions include:
1. How does contamination risk to surface and subsurface water quality change as a result of livestock use within the City?
2. What assumptions concerning manure storage were used when estimating contamination risk to water?
3. What risks were estimated for disease transmission between animals and humans within the City?
4. What separation distances between residences and livestock were deemed to be sufficient to minimize conflict over manure odours?The questions result because OPA 48 will allow urban agriculture in all designations except for those lands which are part of the Natural Heritage System (section 9.1.1 in OPA 48 – quoted in Appendix 1 of this letter). Urban agriculture is proposed to include small-scale livestock production as well as limited urban agricultural product sales. Therefore, for example, given the wording within the OPA, it can be interpreted that chickens, hogs and beef cattle are proposed to be allowed to be raised within a residential area and meat products ranging from a side of beef to pork chops could be sold from the property where the livestock is being produced.
What assumptions were made by the City of Guelph with respect to livestock feed production and storage, manure storage and disposal, animal slaughter, meat storage and sales for “urban agriculture” could not be ascertained by the authors of this letter.
Generally, livestock production in areas of higher human population density is discouraged given risks associated with water contamination and with the probability of disease transmission between animals and human beings. If livestock is considered only from the viewpoint of nuisance, manure odours are a source of conflict within agricultural and rural areas and this conflict has resulted in the formulation of Minimum Distance Separation Guidelines and calculation methods in Ontario. The higher density of noses sensitive to manure within an urban area is likely to result in more complaints than complaint levels currently experienced within agricultural/rural areas.
The information reviewed in support of the contents of this letter provides evidence that the proposed OPA 48 for the City of Guelph cannot meet parts of section 2.2 Water, of the Provincial Policy Statement (2005) which includes the statement that planning authorities must implement necessary restrictions on development and site alteration to protect all municipal drinking water supplies and designated vulnerable areas. Additionally, the City may not be able to meet the requirements of section 1.1 of the PPS (2005) that includes the statement that healthy, livable and safe communities are sustained by … Avoiding development and land-use patterns which may cause environmental or public health and safety concerns. .
Therefore, it is recommended that the wording in the proposed OPA 48 be changed to prevent livestock production within the built up area of the City of Guelph. MH